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The European pulp and paper sector has a long expertise in bioeconomy and has a significant role in providing solutions to many global challenges such as climate change, urbanization and ageing with using sustainable renewable materials. The European pulp and paper sector also offers easily recyclable solutions and answers to EU Circular Economy, Strategy on plastics in the circular economy and the UN Paris Agreement. Our sector operates in a circular way and resource efficiency is at the core of our operations. The growth volume of forests in Europe exceeds their use. Ensuring the growth of forests and their sustainable use is an important part of sustainable bioeconomy.

In its “2050 Roadmap to a low-carbon bioeconomy”, CEPI foresees that a growing part of the value added generated by the pulp and paper industry in Europe will come from breakthrough technologies and from the provision of a wider range of bio-based products, beyond pulp and paper. These products will contribute simultaneously to:

• a massive reduction of greenhouse gas emissions,
• substituting fossil-based materials,
• a transformation from a fossil-dependant economy to a renewable economy,
• fulfilling a number of sustainability challenges (as identified by the United Nations with the Sustainable Development Goals (SDG)).

To achieve a competitive circular bioeconomy, stable and enabling policy conditions in various fields (including environment, infrastructure, transport, energy, agriculture, etc.) must be in place. The review of the 2012 European Bioeconomy Strategy provides the opportunity to set up such conditions. CEPI welcomes it and wants to be an active partner in preparing a new Circular bioeconomy strategy for Europe.

The assets of our industry in the bioeconomy

1. What did the existing strategy deliver that the paper industry welcomes?As confirmed in the review of the 2012 Strategy that has been publicised in November 2017 , the strategy has deliverd several positive results that the European paper industry welcomes.
Its mere existence has raised awareness on the likely benefits that the bioeconomy can bring to Europe’s economy and environment and therefore placed it on the policy radar screens. It has enabled the setup of an Institutional Public-Private Partnership, the Bio-based Industries Joint Undertaking (BBI-JU), endowed with a EUR 3.7 billion budget over 7 years to support research, innovation, demonstration and flagship installations, and which has proved to be a success.
It has also triggered the development of several national and regional bioeconomy strategies that further amplify and tailor the benefits of the bioeconomy to the local circumstances.

2. The bioeconomy potential to address grand societal challengesThe smart development of a circular bioeconomy in Europe will contribute to remedy a number of critical environmental, economic and social challenges. Renewable and recyclable bio-based products:
• must be part of the climate change mitigation policies, thanks to their ability to store carbon, but also to avoid emissions of greenhouse gases from fossil-based or GHG intensive products that they are replacing
• help take environmental responsibility and achieve economic benefits through self-sufficiency (use of mainly locally sourced renewable resources and recycled resources).
• help limit the extraction and depletion of non-renewable resources.
• can reduce the amount of waste landfilled or spread in the environment (land and sea) thanks to their recyclability, but also their biodegradability and compostability.
• contribute to rural development and livelihood, as they depend on natural renewable resources growing on land and in the marine environment.

3. Towards a successful circular bioeconomy strategyWhat makes the paper industry unique is both the renewable biomass and recyclable feedstocks , grown , renewed and recycled in Europe. This contributes to a genuinely circular bioeconomy. In order to enhance the contribution and benefits of the circular bioeconomy to Europe’s economy and environment, CEPI calls on the EU to put further emphasis in the updated strategy on:
• Increasing the availability and mobilisation of biomass (including its transport): this requires notably the promotion of active forest management, the redress of policies that distort biomass supply chains and the adjustment of waste legislation to promote the recycling and recovery of waste and notably of the biomass in the waste.
• Boosting investors’ confidence, notably by de-risking investments made in Europe, and directing EU money (ESIF, EFSI, Research and Innovation) to sustainable sectors in a predictable and stable manner.
• Easing access to markets for a wide range of bio-based products by lifting obstacles to their circulation within the single market and by indicating clear preference for sustainable, circular and bio-based products.

4. Implementing concrete, measurable and time-bound actionsNext to updating the strategy, the related Action Plan must focus on a limited number of actionable and realistic actions that should be implemented in the short term.
• Capitalising on its current success (investments triggered, SME participation, leapfrogging innovations, …), the Bio-based Industries Joint Undertaking must be reconducted with at least the same budget.
• Research and innovation must remain a priority of the EU. The next Framework Programme for Research must factor in a “mission” that targets the climate challenge thanks to sustainable renewable resources.
• The development of a sustainable and circular bioeconomy must be a shared ambition across the European Institutions. Synergies and leverages within complementary policy initiatives must be seeked and enhanced, especially when it comes to the Circular Economy Package and the Climate and Energy policies.
• There must be mechanisms established – e.g. under rural development policy of the CAP –to boost the sustainable production of biomass, allowing for sharing the benefits of the bioeconomy between biomass producers and bio-based industries, while taking care of land, soil, water and biodiversity.
• Separate collection and sorting of biodegradable waste streams (incl. paper and board products) must become the standard and waste lanfilling must be effectively drastically restricted or banned in order to increase both the quality and quantity of waste feedstocks that can be recycled into high value bio-based products.
• Specific funding programmes (including venture capital) should be established to support technology transfer and entrepreneurial iniatives.
• While there exist already provisions for greening public procurement, such policy must also prescribe a preference for bio-based products (inspired by the US Bio-preferred programme). As public buyers, the EU Institutions themselves can already play an exemplary role.
• It is also of utmost importance to overcome misconceptions and misunderstandings concerning the bioeconomy. Ensuring the rapid availability of undisputable data and facts on the expected environmental, climate, social and economic benefits of the bioeconomy and bio-based products, is a must in order to raise awareness and promote the bioeconomy across Europe’s society at large.

1Review of the 2012 European Bioeconomy Strategy, European Commission, Directorate General For Research and Innovation, November 2017, https://publications.europa.eu/en/publication-detail/-/publication/a81308e3-cf37-11e7-a7df-01aa75ed71a1/language-en

Signatories of this letter welcome the Clean Energy Package as the means to set in place new rules for a consumer-centred European energy system, by implementing the three stated EU objectives: putting energy efficiency first, achieving global leadership in renewable energies and providing a fair deal for consumers.

Demand side flexibility is a resource that not only benefits and empowers individual consumers, both private and professional, but also reduces total system costs, facilitates renewables integration and contributes to building Europe’s smart energy leadership.
This remarkable resource however suffers from important market failures that the ‘Clean energy for all Europeans’ package attempts to address. Signatories of this letter, all strong advocates for demand side flexibility, urge you to include the necessary proposals to develop demand side flexibility in the final legislation, and ensure consistent enforcement through thorough planning and reporting obligations in the Governance regulation report.

The stakes are high. Not delivering Europe’s demand side flexibility potential risks affecting Europe’s competitiveness, undermining its decarbonisation efforts, undermining its benefits for consumers and jobs and growth opportunities for Europe as a whole.
The following points highlight key steps necessary to develop demand side flexibility by creating functioning wholesale energy markets; opening markets to consumers and third parties; and remunerating demand side flexibility fairly.

1. Creating functioning wholesale energy markets
The electricity directive and regulation can significantly contribute to establishing well-functioning energy markets that reflect the availability or scarcity of supply and the adequacy of the network. In particular,
• Reform short-term markets functioning to help increase the overall flexibility of the power system (Electricity Regulation Chapter 2).

• Harmonise features of intraday and balancing markets to encourage trading of energy across borders, and as close as possible to the time of delivery (Electricity Regulation, Articles 5 and 7).

• Tackle overcapacity of generation to re-establish long term price signals for investors and minimise the risks that capacity mechanisms create for the development of efficient wholesale markets, as well as consumer empowerment, demand response and the deployment of innovative low carbon and energy efficiency technologies. The best way to minimise such risks is to:

o Only implement capacity mechanisms as a last resort, when proven strictly necessary by a European adequacy assessment which factors in the contribution of renewables, self-consumption and on-site generation (including cogeneration) and assesses flexibility needs (Electricity Regulation, Article 18).
o Ensure capacity mechanisms are open to all resources such as energy efficiency, demand response, storage, all generation technologies, and cross border capacity (to add to Electricity Regulation, Article 23).
o Review the need for capacity mechanisms regularly:
- So as to ensure consistency between procurement of capacity and the size of the adequacy concerns (to add to Electricity Regulation, Article 23) on the basis of the latest European resource adequacy assessment
- So as to ensure consistency with the overall competitiveness and decarbonisation objectives
o Ensure that the duration of the capacity contract is short enough to correspond to the regular reviews.
o Require Transmission System Operators (TSOs) to report on redispatch and countertrading measures they undertake, including underlying costs, and the level of effectiveness and openness of market-based curtailment or re-dispatching mechanisms to all energy resources. In turn, the creation of liquid and efficient markets and the deployment of demand side flexibility resources will reduce the need for additional measures to guarantee system adequacy.

2. Ensuring market access for consumers and third parties

Rules must be established and enforced so that demand-side resources have unhindered access to all energy markets (wholesale, balancing, ancillary services) in all timeframes, including through product requirements fit for supply and demand-side resources alike. This also means direct market access for consumers and new market entrants, including third party aggregators and ESCOs.
In particular:

• Give consumers the right to participate in energy markets with dynamic price contracts. This includes providing customers information on actual time of use at near real time and the right to respond to price signals, as well giving consumers the right to sell flexibility independently of any contractual arrangements to procure energy, directly or through an (independent) aggregator. Smart metering is a pre-requisite as the certified basis for billing consumer using multiple tariffs for market-based pricing. It also forms the foundation for the development of additional consumer services (Electricity Directive, Articles 11, 17, 20, 21).

• Enable fair market access for Demand Response and service providers. Deployment of demand side flexibility has so far been impeded by outdated market rules, insufficient market access for service providers and ineffective price signals. Demand response should have non-discriminatory access to all markets (Electricity Regulation, Articles 1, 3, 4, 5, 6, 7, 11, 12, Electricity Directive, Articles: 3, 15, 16, 17) and Demand Response Aggregators should be enabled to access the market without prior agreement of other market parties who are often competitors (Electricity Directive Article 17).

• Network tariffs should be fully transparent and allow the development of self-consumption and self-generation. They should be based on the marginal costs of the use of the system and take into account the avoided capital (e.g. grid investments) and operational expenditures due to flexible generation and flexible load embedded at the local level, as well as avoided CO2 emissions. (Electricity Regulation Article 16; Electricity Directive Article 15).

• Accelerate the cost-efficient decarbonisation of the existing building stock, notably through reaping the flexibility benefits of technical building systems and other appliances to support consumer empowerment: set in place a proper framework for the deployment of infrastructures (i.e. on-site renewable electricity generation, high efficiency cogeneration, smart metering or electro-mobility) and of demand-responsive devices that will facilitate the buildings’ integration into a wider energy ‘eco-system’ where active prosumers self-generate, self-consume, aggregate, trade and sell surplus electricity to the grid. In this new setting, buildings will no longer be a load but a micro-energy hub contributing to consumer empowerment and cost-efficiency of the energy system. The smartness indicator of buildings should support consumer empowerment and the development of buildings as part of the energy system.

• Create a comprehensive framework for grid monitoring, so as to increase the visibility of flexibility, including demand-side flexibility. It should be based on information that TSOs and DSOs would publish regularly as regards to the performance of their networks , in particular the volumes and sources of curtailed energy (Electricity Directive, Article 59). Comprehensive reporting on grid evolution, together with appropriate tariff structure, will be an essential basis for cost-effective network management and enable the targeted acquisition of flexibility services from the market by system operators instead of CAPEX only investments (Electricity Directive, Article 32).

• Ensure enforceability of the right for citizens and businesses to self-generate, self-consume, and valorise their flexibility; (Electricity regulation Article 16; Electricity directive Article 15).

• Establish a constructive framework for energy storage which takes into account the specificity of the energy storage technologies, and recognizes that TSOs and DSOs should not own, develop, manage or operate storage assets, unless a market based procurement based on an open and transparent tendering procedure is proven of not being possible and is regularly reviewed. (Electricity Directive, Articles 36 and 54)

Signatories of this letter are convinced that such a way forward will provide consumers with the satisfaction of managing their own energy consumption while optimising their overall carbon and environmental performance.

We, the Alliance of Energy Intensive Industries representing more than 30,000 companies that are Europe’s largest energy consumers and together, directly employ more than 2.8 Million people, want to make a success of the Energy Union. We see it as a potential enabler of European industry’s competitiveness and a unique opportunity to deliver on Europe’s ambitious transition to a low-carbon energy system. Energy Intensive Industries make a series of recommendations to reach this ambition in an effective, secure and cost-conscious way that delivers value for investment to European economic contributors such as industry. The Alliance would welcome a new energy framework that:

- ENABLES INNOVATION IN INDUSTRY SECTORS THAT DEVELOP PRODUCTS AND TECHNOLOGIES leading to lower greenhouse gas emissions (GHGs) across value chains. Our industries offer low-carbon solutions to help Europe transitioning to a low-carbon, energy efficient region. Our products and innovative processes have a strong potential to enable greater energy efficiency or help the wider deployment of renewables;

- PUTS THE GLOBAL COMPETITIVENESS DIMENSION HIGH Our industries will be key in delivering several elements of the Clean Energy Package. The Governance of the Energy Union must acknowledge this and not relegate the competitiveness dimension as secondary to other aspects, but increase its prominence;

- SECURES INDUSTRY’S ACCESS TO COMPETITIVE, RELIABLE, AND SUSTAINABLE ENERGY through a fully liberalised European electricity market. The growing share of variable renewable energy production in the grid represents both a challenge and an opportunity for industry. Negative impact of system changes on industry and on security of energy supply must be avoided. Policy framework conditions should be nondiscriminatory, technology-neutral and predictable over the longer term to enable sustainable investment decisions;

- AVOIDS COSTLY AND UNNECESSARY OVERLAPPING LEGISLATION: The EU ETS and the Market Stability Reserve will lead to a higher price of carbon under the 2030 framework. It is therefore important that new measures do not overlap with ETS, adding an additional layer of obligations for industry, but rather target untapped potential laying in e.g. buildings or mobility sectors. Enabling better energy performance in those sectors would stimulate our economy and create new jobs and growth opportunities;

- CLEARLY DIFFERENTIATES ENERGY EFFICIENCY AND REDUCTIONS IN INDUSTRIAL ACTIVITY: looking at levels of energy consumptions in the different sectors of our economy, it is clear that so far the 2020 objective is being partly met through reduced levels of production. Our industries wish to contribute to growth in Europe while, at the same time, improving their energy efficiency performance; in this framework, it is relevant to assess reduction of energy consumption in relative terms;

- INTEGRATES RENEWABLE ENERGY SOURCES IN A COST-EFFICIENT MANNER: as long as it is in place, support to renewable energies must become cost-efficient and must focus on technology-neutral innovation. Support
schemes should be market-based and market responsive. They should only benefit technologies that are not yet mature, on a temporary basis.

As key players in the transition to a low-carbon economy, energy intensive industries and value-chain partners will provide constructive input into the decision-making process.

The Parliament, the Council and the Commission enter now the trilogue negotiations that will shape the ETS directive after 2020.

We, the 17 signatories of this paper, energy-intensive sectors representing about 2 million jobs in the EU and comprising many SME’s, are fully committed in taking our share of responsibilities and reducing our emissions.
However, we are also very concerned by the impact that some proposed measures would have on our global competitiveness.

We stand by one principle: sufficient free allowances must be available to allocate every carbon leakage installation at the level of the benchmark, as to avoid additional direct and indirect costs, resulting from the implementation of the ETS that are not faced by our non-EU competitors.

This is true more than ever, especially when some measures, which have been proposed without any impact assessment on our sectors, might have a dramatic impact on our competitiveness if adopted without the necessary flexibility in the share of free allocation, like the permanent cancellation of allowances, or the doubling of the intake rate of the MSR.

We therefore ask the trilogue negotiators to acknowledge, in their final compromise, the mutual importance of our sectors for the EU economy, in particular for European jobs, and all our economic value chains by:

1) Ensuring enough free allowances are available to allocate all carbon leakage installations at the level of the benchmark. This is not a free lunch for industry as less than 5% of the installations will receive enough to produce, the remaining 95% will have to buy allowances. We therefore support the Parliament proposal to reduce the auctioning share by max 5% (from 57% to 52%) if the CSCF is necessary.

2) Rejecting any approach which aims at discriminating a few from other sectors exposed to carbon leakage risks, namely the “tiered CSCF” in the event that the 5% reduction mentioned above is not sufficient. This discrimination between industrial sectors goes against the principle set in the October European Council Conclusions that best performing companies in ETS carbon leakage sectors should not bear further carbon costs. Indeed, a tiered CSCF would entail that even best performers in most sectors would bear significant carbon costs.

3) Supporting the proposal from the Parliament by which the Innovation fund is fully financed from the auctioning share.

Subject: Alignment of the revision of the Renewable Energy Directive with the Circular Economy Policies

Dear Members of the ITRE Committee,
Ahead of the report of the ITRE committee on the revision of the EU Renewable Energy Directive (RED II), the undersigned organisations, representing plastic and paper recyclers and zero waste associations around Europe, would like to bring to your attention our concerns as regards to inconsistency of the Commission’s proposal in RED II with the Circular Economy policies and the EU’s climate policy agenda.

This is due to the consideration of the biomass fraction of mixed municipal solid waste as a source of renewable energy when it is actually burning thanks to other materials (e.g. plastics and paper). Member States are consequently allowed to support various forms of energy generation from waste, to meet targets set under the RED II. These schemes which support waste-to-energy generation from mixed municipal waste, run counter to the EU’s transition to a low-carbon and circular economy, furthermore this would work to:

1. Undermine the Waste Hierarchy and the Circular Economy policies
Financial support for waste-to-energy from mixed municipal waste subverts one of the cornerstones of the EU waste policy – the waste hierarchy -, which establishes an order of priority in waste prevention and management i.e. prevention, preparation for re-use, recycling, other recovery (energy recovery), and disposal1. Waste is therefore meant to be firstly prevented, then prepared for reuse and, finally, recycled. Conversely, the RED II classifies it as a source of ‘renewable energy’ and allows renewable energy support schemes that conflict with the waste hierarchy by encouraging waste-to-energy processes, which is the second least desirable option of the waste hierarchy.

The effect so far has been a clear distortion of the market whereby investment in waste infrastructure and operation costs are organised on the basis of subsidies for the extraction of energy from waste instead of sound environmental and economic performance of the best waste management option. As a result, several European countries e.g. Denmark have overinvested in energy-from-waste plants whilst underinvesting in recycling facilities.

2. Undermine the Communication on Waste-to-Energy in the Circular Economy
The RED II also contradicts the Commission’s recent Communication on the Role of Waste-to-Energy in the Circular Economy which states that public financing of waste management, whether national or at EU level, should be consistent with the waste hierarchy and Member States should phase-out public support for the recovery of energy from mixed waste in line with the separate collection obligations and more ambitious EU recycling targets proposed in the legislative proposal on Circular Economy2.
1 http://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf
2 http://ec.europa.eu/environment/waste/waste-to-energy.pdf

3. Undermine the EU’s Climate Policy Agenda
The Commission’s proposal also undermines the EU’s climate agenda by supporting energy generation from mixed municipal waste, which is never solely composed of biogenic carbon. Much of the calorific value from waste-to-energy processes from mixed waste (incineration, pyrolosis or gasification) comes from the treatment of fossil carbon based materials such as plastics. For example, a typical waste incineration facility has a carbon intensity of approximately 600 kg CO2 eq. per MWh of electricity. This compares with a figure of 380 kg CO2 per MWh of electricity at an efficient natural gas power station using Combined Cycle Gas Turbine technology3.
Moreover, the monitoring of the amount of the proportion of organic waste compared to the amount of fossil-based waste in municipal mixed waste is both logistically and technologically difficult. It’s often assumed that the proportion is 50% - even if industrial and commercial waste is frequently included in the mix of waste entering a waste-to-energy facility. Given the heterogeneity of waste and the great differences from plant to plant, this percentage is neither constant nor reliable, which supports the evidence that much of the so-called renewable energy from waste-to-energy comes in fact from incinerating fossil carbon based materials.

The undersigned organisations therefore urge the members of the ITRE Committee to align the Commission’s proposal for a revised Renewable Energy Directive with the circular economy policies by explicitly excluding primes of subsidies for waste-to-energy generation from the mixed municipal solid waste.

CEPI position on the Commission proposal for a regulation on the inclusion of GHG emissions and removals from LULUCF into the 2030 climate and energy framework

Main Goal:

The main goal for the European pulp and paper industry in the debate on climate change and forestry is to work on a policy framework enabling the long term sustainable management of European forests. This is in line with the conclusions of chapter 9 of the 4th Assessment Report of the International Panel on Climate Change (IPCC): “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitigation benefit.”

Main Concern:

The main concern of the European pulp and paper industry is that proposals for the inclusion of GHG emissions and removals from LULUCF focus on the 2030 horizon and forest sequestration. Meanwhile the potential of the other aspects of sustainable forest management such as the absorption of carbon by more dynamic forest management and storage and substitution of wood products replacing fossil based ones would not be sufficiently recognised and harvesting levels would be reduced.

The European pulp and paper industry is a key contributor to the bioeconomy. It uses wood from sustainably managed forests to produce renewable and recyclable products which substitute more carbon intentive products.. In addition, the European pulp and paper industry produces bioenergy with highly efficient combined heat and power generation. Further increasing the efficiency of the wood use, the industry is developing new products based on wood to grow the bioeconomy and even more substitute fossil based materials. The mitigation potential could be further improved by further supporting the growth of forests, dynamic forestry and the mobilisation of wood, the use of wood-based products, high value added products, the cascading use principle and strengthening innovation in new bio-based products.

Accurately accounting the emissions/removals from the sector is crucial to demonstrate that European forests and the use of its products have a positive contribution to climate change, as forests absorb carbon from the atmosphere and sequester it. Harvested wood products store carbon and substitute fossil based products. Along the chain, wood, harvesting residues and industrial residues are also used to produce bioenergy substituting fossil fuels. (Replacing fossil fuels by bioenergy is an interim target on the way to bio-based value chains creating high value added from products, materials and fuels.)

In the last decades, forests in Europe have been growing both in surface and in growing stock. Looking ahead, Chapter 9 of the 4th Assessment Report of the IPCC states: “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitgigation benefit. Most mitigation activities require up-front investment with benefits and co-benefits typically accruing for many years to decades. The combined effects of reduced deforestation and degradation, afforestation, forest management, agro-forestry and bioenergy have the potential to increase from the present to 2030 and beyond”. The combined climate change mitigation effect should be maximised. Therefore disproportionate measures on one of these elements should be avoided.

In this context CEPI and its members welcome the recognition of forests and forest products in the EU’s new climate and energy policy framework 2020-2030 and the inclusion of the land use, land use change and forestry sector in the framework.

Even though the proposal is on a 10 year period, it should incentivise the long term carbon benefits of forests and the bio-economy. The inclusion should not lead to an optimisation for the 2020 to 2030 period. In the long term, Europe will need more wood products.

The regulation should provide a framework incentivising Member States to promote a forest management, which increases the capacity of its forests to take carbon out of the atmosphere and at the same time store it in products that substitute fossil products.

The Commission proposal includes several positive principles:

Emissions from the land use sector are reported when harvesting takes place. Carbon emissions should be accounted once. Emissions from the combustion of biomass should therefore accounted as zero to avoid double counting. This also ensures the climate effect of the wood use is allocated to the country in which the trees are harvested.

Harvested Wood Products (HWP) are recognised as carbon pools contributing to the mitigation efforts. We believe this is a very important element of the framework, as HWP provide a mitigation potential well below the 2020-2030 period.

Flexibility between LULUCF and the effort sharing sector is limited to afforestation. This gives Member States with potential for afforestation the possibility to use this abandoned land for afforestation. The potential for afforestation is varying strongly between Member States. However, we believe it is not necessary to limit this flexibility to 280 million tons of CO2. There should not be flexibility between LULUCF and effort sharing sector for forest management.

We believe that the Commission should continue work towards international progress in carbon accounting and encourage other world regions to account for their emissions from LULUCF, particularly countries from which the EU is sourcing wood for bioenergy and products. A credible and though workable scheme in Europe could facilitate the uptaking of similar initiatives in other world regions. Such bottom-up approach has proven successful in the Paris agreement.

Finally we welcome the fact that the proposal is directed to the Member States rather than smaller entities. This ensures the contribution from forestry is regarded upon in landscape approaches and with long time frames.

The Commission proposal contains provisions to be improved:

The framework should be comprehensive and as flexible as possible to further allow Member States to develop policies based on their national conditions.

Forest management reference levels should be set on the basis of long timeframes in order to better reflect trends and responses to climate change policies and measures already in force. These timeframes should enable reference levels to emphasise the impact of most recent policy instruments affecting forest resources, forest management and use of forest products in the country.

The setting of projections based on reference levels has to be credible and transparent and should be based on subsidiarity in forest related issues. The European Commission’s role should be focused on ensuring harmonised country established reference levels and on ensuring credibility and transparency rather than a centralised recalculation on those national elements.

The criteria for the establishment of forest reference levels should be reviewed and better focused on carbon relevant criteria. Biodiversity conservation is already addressed in specific EU and national legislation and this should be reflected in policy.

The option chosen by the Commission is based on the no-debit rule. CEPI believes the no-debit rule is crucial in the LULUCF proposal to demonstrate that the forest sector acts as a sink. However, we believe that Member States demonstrating they harvest less than the net annual increment should not be sanctioned.

In view of the European Commission's publication of its Winter Energy package, the European paper industry has compiled a position paper outlining its stance on key aspects of the proposal. Here are our key messages:

Deliverables expected by “Clean energy for all Europeans” package, as a whole:

 Electricity markets
• Allowing for market-based prices to show real value of electricity
• RES generators should participate in the markets in the same way as all other generators
• Subsidies to RES-E should not be allowed to distort wood supply markets
• Security of electricity supply to energy intensive industry must be secured
• Demand flexibility should be voluntary and rewarded
• The benefits of CHP should be recognised (efficiency, cost effective, energy security, resource efficiency)
• EU should not create more bureaucracy or official bodies / authorities

 Energy Union Governance
• No to a binding cap on energy consumption impeding industrial growth
• Increased mobilisation of forest biomass is essential in reaching the 2030 renewable energy target
• Need for a real focus on industrial competitiveness
• Reduction of administrative burden for business needs to be prioritised
• Need to avoid/minimise policy conflicts and overlaps

 Energy Efficiency
• The directive should not set a binding EU cap on energy consumption
• Member States should be allowed to set their own indicative targets
• Costs and potentials varies across Member States: there is no one-size-fits-all energy savings trajectory
• Equal footing between obligation schemes and alternative measures needs to be preserved
• Cogeneration to remain at the core of the Energy Efficiency Directive

 Renewable energy
• Support schemes should not distort wood markets and should stimulate supply of wood
• Opening up to national schemes to cross-border participation in electricity markets should lead to more market integration, not to harmonised subsidies
• Guarantees of origin should remain as trade description, not to be used as subsidies
• There is no “one size fits all” in heating and cooling: focus should be on flexibility and cost-efficiency
• Emission reduction in transport should cost-efficiently drive renewable energies in transport (RES-T) integration into the market while not resulting in transportation costs increased
• Our industry is an emerging producer of RES-T solutions mainly from wastes and residues, such as advanced biofuels, biogas, excess electricity from bio-based pulp and paper mills...
• Bureaucracy and costs should be avoided when implementing sustainability criteria

Europe‘s metals, steel and paper industries renew their call for a harmonised method to measure Member State recycling rates at input into the 'final recycling process'.
The full document can be consulted via the link below.

We welcome the European Commission’s intention to create a technically interoperable system in all Member States. However, the introduction of any distance-based road charging measure will inevitably be more costly. Road charging should not result in penalising of the road. It should respect the level playing field between different modes and not disturb the market conditions.